Deadline Looms for Issuers to Share SOX 404 Costs with SEC

Public companies
have until Jan. 31 to take advantage of an opportunity to give input
to the SEC on their experience with Sarbanes-Oxley (SOX) section 404
implementation.

The SEC has
solicited feedback through a voluntary survey as part of its ongoing
cost-benefit study of SOX section 404 implementation. “We encourage
all companies with Section 404 experience to participate,” James
Overdahl, the SEC’s chief economist said in a press release. “The
survey provides companies with an opportunity to share their
experiences and provide a comprehensive set of facts on the
effectiveness and efficiency of compliance with the rules
established pursuant to section 404.”

The survey, which is open to any
company with section 404 compliance experience, was slated to close
Jan. 16 but has been extended to Jan. 31. User IDs and passwords
required to complete the survey were sent to SEC registrants. If you
have lost your survey password or would like to request one, send a
request with your name, title and company to 404survey@sec.gov.

The SEC plans to
pay special attention to smaller companies that are scheduled to
begin complying with section 404(b) requirements at the end of this
year, according to an SEC press release.

The SEC’s
cost-benefit study will help the Commission assess the effects of
measures taken by both the SEC and the PCAOB in previous years,
including whether the measures have helped companies reduce their
compliance costs and whether the Commission should consider
additional measures. These measures include SEC
guidance for management’s Section 404 assessment, which was
issued in 2007, and the PCAOB’s effort to make the Section 404(b)
auditor attestation process more efficient.